The BodyWell Method
Privacy Policy
Effective Date: October 6, 2026
Last Updated: October 6, 2026
This Privacy Policy (“Policy”) explains how TBW Method Inc., doing
business as The BodyWell Method (“TBW,” “BodyWell,” “we,” “us” or
“our”), collects, uses, discloses, retains and protects Personal
Information in connection with bodywellmethod.com, The BodyWell Method
mobile application, any supported television application, and related
digital services and communications (collectively, the “Services”).
“User,” “you” and “your” refer to the individual whose information is
processed.
“Personal Information” means information that identifies, relates to,
describes or can reasonably be linked to an identified or identifiable
person. It includes “personal data,” “personal information” and
equivalent terms under applicable law. TBW determines the purposes and
means of processing described in this Policy and is the responsible
business or controller where those concepts apply.
The BodyWell Method provides on-demand, self-guided movement,
recovery and recipe content. Although physical therapists help develop
and lead the content, the Services do not diagnose or treat User and do
not create a patient relationship. That distinction does not remove the
privacy protections applicable to health-related information. Our
separate Consumer Health Data Privacy Policy explains
additional protections and rights for consumer health data and is
available through its own link on the website and in the app.
Acknowledging this Policy or accepting the Terms is not
consent to optional marketing, non-essential tracking, or processing of
sensitive information where separate consent is required. TBW requests
such permissions separately.
1. SCOPE; OTHER SERVICES.
This Policy covers information collected through the Services,
account and subscription administration, customer support, privacy
requests and related communications. It does not govern an independent
app store’s, payment provider’s or other third party’s own processing,
which is described in that provider’s policy. Information processed by a
vendor on TBW’s behalf remains subject to TBW’s responsibilities and
applicable contractual safeguards; using a vendor does not remove those
responsibilities.
The Terms and Conditions of Service govern the service relationship.
If a general provision of this Policy conflicts with a more protective
consumer-health-data requirement, the specific health-data requirement
controls. This Policy does not authorize collection of a category or use
for a purpose for which additional notice or consent is legally
required.
2. INFORMATION TBW COLLECTS.
The information processed depends on the Services User uses and the
information User chooses to provide. TBW distinguishes information
needed to administer an account from optional wellness information used
for a requested feature.
2.1. Account and contact
information.
For account registration, TBW currently asks User to provide a name,
email address and password. TBW also maintains authentication
credentials, account and language preferences where available,
communication choices, account status and subscription status as needed
to operate the account. User may provide a telephone number or other
contact details when communicating with support, but an ordinary support
request should not include unnecessary sensitive information.
2.2. Purchases and billing
information.
Selected plan, payment and renewal status, transaction identifiers,
billing history, receipts, refund and cancellation information, billing
name and address, and limited payment details made available by a
payment provider, such as card brand, last four digits and expiry.
Website card payments are processed by Stripe. Full card numbers and
security codes are entered with the payment provider rather than stored
by TBW. For an app-store purchase, TBW receives purchase or entitlement
information rather than User’s full payment-card details.
2.3.
Voluntary wellness information and content preferences.
TBW does not currently require a wellness questionnaire to create an
account. If an optional movement-goals questionnaire is introduced, it
may ask User to select general goals such as daily wellness, mobility, a
special condition or strength so that TBW can organize relevant movement
content. Any response that identifies or suggests a health condition is
handled as sensitive information where applicable. TBW does not
currently ask Users to upload body scans or progress photos as part of
account setup. A health-related detail included in a support message is
also handled as sensitive where applicable. TBW will provide an
appropriate collection-point explanation and obtain any required
separate consent before processing optional health information.
2.4. Content and
communications User sends.
Support emails, questions, feedback, complaints, privacy requests,
and any comments, reviews or profile material User submits through an
available feature. Material sent by User may include sensitive
information even if TBW did not request it. Only material expressly
submitted for public display is intended to be made public. Do not
include another person’s private information or unnecessary health
details in a public submission.
2.5. Usage, viewing
and engagement information.
Videos or other content accessed, playback progress, favorites,
scheduling selections, app openings, feature interactions and
subscription-related activity. This information helps provide access,
resume content, remember choices, diagnose problems and understand use
of the Services. When it identifies or is used to infer a person’s
health status or health-related interests within an applicable
health-data law, TBW treats it as consumer health data rather than
assuming it is ordinary analytics. TBW does not infer health conditions
for advertising.
2.6. Device and technical
information.
Device type, operating system, browser and app version, language,
time zone, IP address, app or device identifiers, notification tokens,
log and diagnostic information, and related security or performance
data. On the website, cookie and similar identifiers may be collected as
described in Section 7. An advertising identifier is subject to
applicable device permissions and tracking restrictions; its
availability does not authorize use of health information for
advertising.
2.7. Approximate location.
TBW may derive a city or region from an IP address for functions such
as localization, security and understanding general usage. The described
Services do not require precise GPS location. TBW does not use precise
location to identify visits to healthcare facilities or create
prohibited health-related geofences. A new location-dependent feature
would require appropriate additional notice and permission before
collecting precise location.
2.8. Sources.
TBW receives information directly from User, automatically from
User’s device and interactions with the Services, and from providers
supporting the requested service. These include VidApp for app
operations and activity information, Stripe for website transactions,
Apple’s App Store or Google Play for applicable purchase and
subscription status, Flodesk for permitted email communications, and
Gmail / Google for User support communications. TBW does not currently
connect to Oura Ring or another health or wearable platform and does not
currently collect body-scan data through a connected feature. If a
wearable, health-platform or body-scan integration is introduced, TBW
will provide a separate explanation of the specific data and source and
obtain any authorization required before collection begins.
3. HEALTH AND OTHER
SENSITIVE INFORMATION.
3.1. Limited purposes.
Where User provides optional wellness information through an
available feature, TBW uses that information to provide the content
suggestions or other wellness function User requests, respond to User’s
related support request, and administer the associated consent and
privacy rights. It is not used to diagnose or treat User. General
service-improvement language elsewhere in this Policy does not authorize
unrestricted secondary use of health information. Improvement analytics
involving health information must be genuinely de-identified or
separately permitted by the applicable notice, consent and law.
3.2. Separate consent.
Where required, TBW obtains a separate, affirmative, purpose-specific
consent before collecting or using consumer health data and a separate
consent before sharing it with a third party. A legal exception for
processing necessary to deliver a specifically requested service is
applied only within its actual scope; it is not a substitute for consent
required by another applicable law. For EEA and UK special-category
health data, TBW relies on explicit consent for optional wellness
personalization, as described in Section 15. A preselected box, general
Terms acceptance or silence is not that consent.
3.3. Withdrawal and feature
choice.
User may decline optional health-data processing and may withdraw
consent by using the relevant available control or emailing
info@bodywellmethod.com. TBW will stop processing based on that consent
and implement any related deletion or downstream notification obligation
required by law. Withdrawal does not affect earlier lawful processing.
The particular feature that depends on the data may become unavailable,
but TBW does not condition unrelated general content or a statutory
privacy right on optional consent.
3.4.
No health-data sale, advertising or third-party model training.
TBW does not sell consumer health data, use it for targeted or
cross-context behavioral advertising, or disclose it to advertising
networks or data brokers for those purposes. This restriction includes
health information revealed by program selections, health-related page
or screen activity, and identifiers linked to such activity—not only the
answers to an intake form. TBW does not use Personal Information to
train, fine-tune or evaluate third-party generative AI models. A service
provider’s operational role does not authorize such a use.
3.5. Limited access and
publicity.
Health information is disclosed only as needed for the limited
purposes described here and in the Consumer Health Data Privacy Policy,
under appropriate restrictions and any required consent. A general User
Content license does not allow TBW to place User’s health information,
image, progress materials or testimonial into an advertisement.
Promotional use requires a separate, specific permission and any
additional health-data authorization required by law.
3.6. HIPAA and other
health-data laws.
The Services are a general-wellness product, not a patient portal or
clinical treatment service. A physical therapist’s involvement in
creating content does not by itself make information collected by this
consumer app protected health information under the U.S. Health
Insurance Portability and Accountability Act (“HIPAA”). User should not
assume that HIPAA applies to the Services. TBW’s obligations under
applicable consumer privacy, confidentiality, health-data and security
laws remain in place; this Policy does not ask User to waive them.
4. HOW TBW USES PERSONAL
INFORMATION.
Subject to Section 3, TBW uses Personal Information to: (a) register,
authenticate and administer accounts; (b) provide paid access and
requested playback, preference and content features; (c) administer
payments, renewals, cancellations, refunds and billing inquiries; (d)
provide optional content suggestions based on permitted information; (e)
answer support questions and resolve complaints; (f) send receipts and
essential subscription, operational, security and legal communications;
(g) send optional marketing where lawfully permitted and consistent with
User’s choices; (h) diagnose faults and evaluate general product
performance; (i) prevent fraud, unauthorized sharing, infringement and
security incidents; (j) respond to privacy requests and keep records of
required notices and choices; and (k) comply with legal obligations and
manage appropriate audits, disputes and business transactions.
TBW limits collection to information reasonably needed for the
disclosed purpose. When User does not provide information objectively
necessary for an account or payment, TBW may be unable to provide that
part of the Services. Failure to provide optional wellness information
does not prevent unrelated basic functionality. TBW does not use broad
business-administration purposes to bypass the restrictions on sensitive
data.
5. USER CONTENT;
RECOMMENDATIONS; AUTOMATED TOOLS.
5.1. Sharing choices.
Private intake answers and support communications are not public
merely because they are submitted to TBW. If an available feature
invites User to publish a review, comment or profile item, the feature
will identify the intended audience. Other people may retain copies of
material User chooses to make public. TBW will act on deletion requests
within the limits of applicable law and its control, but cannot promise
to erase a copy independently retained by another person.
5.2. Recommendations and
automation.
Content suggestions may use User’s preferences, permitted intake
answers and interactions to organize material relevant to those choices.
They are educational selections, not clinical decisions. Operational
tools may also support account access, playback, security and
troubleshooting. TBW does not use the described wellness recommendations
to make a solely automated decision producing legal or similarly
significant effects on User. If a new feature involves that kind of
decision, TBW will provide the required explanation, human-review or
challenge rights and other safeguards before introducing it. Health-data
requirements apply to inferences as well as to source information.
5.3. AI restrictions.
The prohibition on using Personal Information for third-party
generative-model training in Section 3.4 applies across the Services.
Neither a vendor agreement nor User’s acceptance of the Terms expands
the permitted purposes stated here. A future AI-assisted feature
involving a new processing purpose requires an appropriate updated
notice and any necessary separate consent; its existence should not be
inferred from this Policy.
6. HOW TBW DISCLOSES
INFORMATION.
6.1. Providers supporting
the Services.
TBW discloses the information reasonably necessary for the provider’s
assigned function. Providers processing information on TBW’s behalf are
subject to appropriate confidentiality, security, purpose-limitation and
deletion obligations. The principal providers identified for the
Services are:
| VidApp — app platform, content delivery, hosting, product analytics
and notifications |
Account identifiers and contact details; app and playback activity;
device and notification data; other information processed within the
enabled app features |
Operates and supports the app and its content. Access to
identifiable health information is limited by Section 3 and the
health-data policy. |
| Stripe — website payments |
Billing and transaction information; payment credentials entered
directly with Stripe |
Processes website purchases, recurring charges and authorized
refunds. TBW does not send wellness intake answers for payment
processing. |
| Apple App Store, Google Play and other supported purchase
stores |
Purchase, entitlement, renewal, refund and cancellation
information |
Administers the store transaction and provides subscription status.
The store’s separate processing is governed by its own policy. |
| Flodesk — email communications |
Email address, communication preferences and permitted email
engagement information |
Sends communications. Health intake answers and health-based
audience tags are not used for advertising campaigns. |
| Gmail / Google — email and customer support |
User’s address, message and attachments submitted to support |
Receives and manages correspondence; unnecessary sensitive
information should not be included. |
| Advertising / marketing pixels or SDKs |
None currently enabled for advertising or targeted-advertising
purposes |
TBW is not currently running advertising pixels or advertising
tools. Before enabling any such technology, TBW will provide the
disclosures and consent or opt-out controls required by applicable law
and will not use consumer health data for advertising. |
6.2. At User’s direction.
TBW may disclose material to the audience User intentionally selects
through an available feature or as separately authorized. An instruction
to make information public is not a general authorization for TBW to
sell it, use it for advertising or disclose unrelated private
information.
6.3. Legal and safety matters.
TBW may disclose information when required by a valid legal
obligation, or when otherwise specifically permitted by applicable law
to protect rights, address fraud or security incidents, or establish,
exercise or defend legal claims. TBW evaluates the scope of a demand and
limits disclosures as required. A generic law-enforcement request does
not override restrictions on consumer health data or applicable legal
process. Notice will be provided when legally required and
permitted.
6.4. Advisers and business
transactions.
Necessary information may be disclosed to professional advisers under
confidentiality obligations and in connection with a genuine merger,
reorganization, financing or business transfer under appropriate
safeguards. A successor must honor applicable privacy duties. This does
not authorize a sale of health data, unrelated secondary use, or a
transfer that lacks a legally required consent or authorization. User
will be notified of a material change affecting how information is
handled.
6.5. De-identified
and aggregated information.
TBW may create and use aggregated or de-identified information for
product and business analysis where the information satisfies applicable
legal de-identification standards and cannot reasonably identify User.
Removing a name alone may not be sufficient. TBW will maintain data in
de-identified form and not attempt re-identification except where
specifically permitted by law to test the effectiveness of
de-identification safeguards. Applicable recipients must be restricted
from re-identifying it.
7. COOKIES, SDKS AND
SIMILAR TECHNOLOGIES.
The website uses cookies and similar technologies for necessary
functions such as authentication, security and remembering relevant
choices. VidApp and other operational providers may use analytics, SDKs,
local storage, device identifiers, notification tokens and diagnostic
tools to operate and support the Services. TBW is not currently running
advertising pixels or other advertising-tracking tools. If non-essential
analytics or marketing technologies are later enabled, they will be
described in the website or app consent controls and the disclosure in
Section 9 before activation where required.
Where consent is legally required, TBW will not activate
non-essential technologies until User has made an affirmative choice.
User may accept, reject or manage optional categories and withdraw a
prior consent through the cookie or privacy controls. Rejecting optional
technologies must not prevent functions that do not need them. Browser
settings may also restrict cookies, but browser controls do not
necessarily govern app SDKs or server-side disclosures.
If TBW later introduces tracking subject to Apple’s App Tracking
Transparency rules, TBW will seek the required device-level permission
before tracking across other companies’ apps or websites. That
permission is not a substitute for any separately required cookie or
health-data consent. No cookie, pixel, SDK or conversion interface may
be used to send identifiable health information to an advertising
provider in conflict with Section 3.
8. EMAILS; PUSH
NOTIFICATIONS; MARKETING CHOICES.
TBW sends necessary account, subscription, security, privacy and
service communications without treating them as optional advertising.
Optional marketing is sent only where the applicable consent or other
permission allows and can be stopped through the message’s unsubscribe
control or by contacting info@bodywellmethod.com. A marketing choice
presented during account creation is separate from the subscription
purchase. Where express consent is required, providing an email address,
accepting the Terms, silence or a preselected checkbox does not by
itself supply valid consent. TBW will honor applicable timing
requirements for unsubscribe requests, including Canadian
commercial-message rules where applicable.
User can manage push notifications through device settings and any
available app control. Turning off marketing or push notifications does
not cancel a subscription. TBW may keep a minimal suppression record to
honor a request not to receive marketing. Personal health information
and health-based audience segments are not used for advertising or
promotional targeting.
9.
NON-HEALTH ADVERTISING; SALE OR SHARING; PREFERENCE SIGNALS.
9.1. Non-health data practices.
TBW does not currently sell Personal Information or share Personal
Information for cross-context behavioral advertising, and it does not
currently use advertising pixels or advertising SDKs for targeted
advertising. TBW uses service and product analytics through operational
providers, including VidApp, as described in Section 6.1; those uses do
not authorize use of consumer health data for advertising. If TBW later
introduces advertising or marketing technologies that constitute a sale,
sharing or targeted advertising under applicable law, TBW will update
this Policy and provide any required consent or opt-out controls before
engaging in that activity.
9.2. Meaning and controls.
“Sale” and “sharing” under some state privacy laws include certain
disclosures to advertising providers even without payment to TBW. TBW
does not currently engage in the non-health sale, sharing or
targeted-advertising activity described in Section 9.1. If that changes,
any such activity will be subject to applicable notice, consent and
opt-out requirements, and User will be given the required privacy-choice
mechanism. A general cookie acceptance does not authorize sale or
advertising use of health information.
9.3. Preference signals and
minors.
TBW honors legally recognized opt-out preference signals, including
Global Privacy Control, where required by applicable law. The signal is
applied to the browser or device and, where required and linkable, the
associated account. Ordinary “Do Not Track” signals are different and
are not treated as a universal privacy instruction unless required by
law. TBW does not knowingly sell or share Personal Information of anyone
under eighteen (18), and the Services are not intended for ineligible
minors. The health-data prohibitions in Section 3 apply regardless of a
User’s advertising choice.
10. RETENTION; DELETION.
TBW retains information only for as long as reasonably necessary for
the disclosed purpose and an applicable lawful basis. Retention depends
on the nature and sensitivity of the data, account status, the requested
feature, legal recordkeeping requirements and a documented need to
resolve a specific matter. TBW does not apply a general tax-record
period to an entire wellness profile.
| Account and preferences |
While needed to maintain the account and requested access; after
closure, only limited records with a specific lawful retention
basis. |
| Identifiable wellness information and health-related inferences |
While needed for the specific requested and lawfully authorized
feature; withdrawn consent and deletion requests are handled under the
more specific health-data rules. |
| Purchases, refunds and tax or accounting records |
For the period required by the applicable tax, accounting or
transaction law, without unnecessary wellness details. |
| Support, complaints and legal matters |
For resolution and a proportionate, documented follow-up or
applicable legal-claim period; sensitive content is minimized. |
| Technical logs and analytics |
For the time needed for security, diagnostics or the disclosed
measurement purpose, then deleted or lawfully de-identified. |
| Consent, opt-out and suppression records |
A minimal record for demonstrating compliance and continuing to
honor User’s choices. |
| Backups |
Under a restricted recovery cycle; not a means to restart active use
or evade an applicable deletion deadline. |
After a valid deletion request, TBW deletes or lawfully de-identifies
the relevant information unless a specific exception applies. A record
retained for legal compliance is access-restricted and not used for
unrelated purposes. Consumer-health-data deletion must reach required
processors, other recipients and backups within applicable deadlines;
the separate health-data policy describes the Washington and Nevada
rules. A general business need or an indefinite backup cycle does not
override them.
11. SECURITY; INCIDENTS.
TBW uses reasonable administrative, technical and organizational
safeguards proportionate to the sensitivity and volume of Personal
Information. These include appropriate access restrictions,
confidentiality requirements and vendor controls. TBW does not guarantee
absolute security or describe a system as risk-free. User should protect
credentials and notify info@bodywellmethod.com of suspected unauthorized
access.
If an incident triggers a notification duty, TBW will notify affected
individuals and the appropriate authorities, and other required
recipients, within the applicable time limits. This includes applicable
consumer-health-data breach obligations; a health-data incident may
involve an unauthorized disclosure, not only a network intrusion. TBW
will not treat the absence of a patient relationship as an exemption
from applicable notification law.
12. CHOICES; REQUESTS; APPEALS.
12.1. How to contact TBW.
Send a request to info@bodywellmethod.com, identifying the request
and account email if applicable, or use the available account privacy
controls. For a consumer-health-data request, use “Consumer Health Data
Request” in the subject line. User may request deletion through the
in-app account-deletion control or by email. No new account is required
to exercise a privacy right. TBW’s contact details appear in Section
19.
12.2. Available rights.
Depending on location and applicable law, User may request
confirmation of processing; access and a copy; correction; deletion;
restriction; portability; information about recipients or a list of
third parties where required; withdrawal of consent; objection to direct
marketing or certain legitimate-interest processing; opt-out of sale,
sharing, targeted advertising or legally significant profiling; and
applicable limits on sensitive-information use. User may also complain
to a competent regulator. TBW will not unlawfully discriminate against
User for exercising a right.
12.3. Verification and agents.
TBW verifies identity and authority only to the extent reasonably
necessary and legally permitted, ordinarily by using existing account
information or confirming control of the account email. TBW will not
request a full payment-card number, password or unnecessary health
details. An authorized agent may act where law permits, subject to
proportionate proof of authority. Verification requirements do not apply
to an opt-out when prohibited by law.
12.4. Timing and limitations.
TBW responds within the deadline applicable to the request. EEA and
UK requests are generally handled within one month; Canadian access
requests are generally subject to a 30-day period; many U.S. state
requests have a 45-day response period. A legally permitted extension
requires the applicable notice and reason. Consumer-health-data deletion
and appeals may have different deadlines. Requests are free where
required, subject only to lawful exceptions. If a request is limited or
denied, TBW will explain the applicable basis and available review or
complaint route rather than rely on a blanket business-purpose
exception.
12.5. Appeals and complaints.
To appeal a decision where an appeal right applies, reply to the
decision email or write to info@bodywellmethod.com with “Privacy
Appeal.” TBW will review the decision and explain the result within the
applicable statutory period. An appeal may be submitted by the same
practical channels as the original request. An internal complaint or
appeal is not a prerequisite to contacting a regulator unless applicable
law expressly requires otherwise.
12.6. Account deletion and
subscriptions.
Deleting account data and canceling a paid subscription are related
but distinct. TBW will stop a TBW-billed recurring subscription when
deleting the related account. A store-managed subscription may require
separate cancellation through the store, as explained before deletion
where reasonably practicable and in the Terms. Uninstalling an app alone
does neither.
13. CALIFORNIA AND
OTHER U.S. STATE DISCLOSURES.
13.1. Categories and purposes.
Where applicable U.S. state law requires category disclosures, the
categories described in Section 2 correspond to: identifiers and
account/contact records; customer and transaction records; internet or
electronic-network activity; approximate geolocation; electronic or
visual communications User submits; preferences and content-related
inferences; and sensitive information, including health information and
account credentials where the law so classifies them. These descriptions
apply to collection and disclosure during the preceding twelve months to
the extent the relevant practice operated during that period, as well as
current practices.
The source categories are User, User’s device and activity, and the
service or transaction providers identified in Section 2.8. Purposes
appear in Sections 3 and 4. The business-purpose recipient categories
appear in Section 6, and retention criteria in Section 10. The Section 9
disclosure identifies any non-health sale, sharing or targeted
advertising and the corresponding data and recipient categories.
13.2.
Sensitive information and state-specific rights.
TBW limits sensitive information to the requested service, security,
rights administration and other specifically permitted purposes. If a
use requires a separate opt-in or a right to limit, TBW will provide the
required control before engaging in that use. This does not authorize
general profiling or advertising from wellness information.
State-specific rights may include obtaining recipient lists or appealing
a decision. TBW will apply those rights when the relevant law covers the
request, including consumer-health-data protections that may apply
independently of general revenue or volume thresholds.
13.3. Direct-marketing
disclosure requests.
California residents may contact info@bodywellmethod.com with
“California Direct Marketing Disclosure” to request information
available under California Civil Code Section 1798.83 concerning
disclosures for a third party’s direct marketing. This request route
does not substitute for a legally required sale/sharing opt-out.
13.4. Consumer health data.
The separately linked Consumer Health Data Privacy Policy addresses
Washington, Nevada and, as applicable, other state consumer-health-data
protections. It describes the health-data categories and sources,
purposes and recipients, consent choices, access and deletion requests,
and appeals.
14. INTERNATIONAL
PROCESSING AND TRANSFERS.
TBW is based in the United States. Personal Information may be
processed in the United States and in other countries in which the
service providers identified in Section 6.1 operate, store information
or provide access to their systems. Depending on the User’s location and
the provider involved, those countries may have different privacy laws
and lawful-government-access rules. TBW will provide additional
country-specific transfer information where required by applicable
law.
Where required, TBW uses an appropriate lawful transfer mechanism and
safeguards, such as an applicable adequacy decision, the European
Commission’s Standard Contractual Clauses and appropriate UK transfer
terms, supported by required assessments and supplementary measures. Use
of the Services or a general acknowledgment of overseas processing is
not consent to waive safeguards. User may request information about, or
an appropriate copy of, the safeguards at info@bodywellmethod.com,
subject to lawful redactions.
15. EEA, UK AND FRANCE.
15.1. Controller and lawful
bases.
TBW is the controller for the consumer-service processing described
here. The EU GDPR and applicable UK data-protection law apply where
their territorial and substantive requirements are met. TBW identifies
the appropriate basis for each purpose as follows:
| Account creation, purchased access, subscription administration and
requested support |
Performance of the contract or pre-contract steps requested by User,
limited to what is objectively necessary. |
| Optional health-based content personalization |
Consent under Article 6(1)(a), together with explicit consent under
Article 9(2)(a) for health data. Contract or legitimate interests alone
is not sufficient. |
| Non-essential cookies, similar tracking and marketing requiring
permission |
Consent, with a practical withdrawal mechanism and any additional
electronic-communications requirements. |
| Proportionate security, fraud prevention, non-sensitive product
diagnostics and ordinary business administration |
Legitimate interests under Article 6(1)(f), after balancing User’s
rights; not a bypass for cookie consent or special-category
conditions. |
| Tax, accounting, legally required notices and privacy-rights
compliance |
Compliance with an applicable legal obligation under Article
6(1)(c). |
| Establishing or defending a specific legal claim |
An appropriate Article 6 basis and, where health data is strictly
necessary, the applicable Article 9 legal-claims condition. |
15.2. Rights and objections.
User may request access, rectification, erasure, restriction and
portability where applicable, and object to processing based on
legitimate interests. An objection to direct marketing will be honored
for that purpose. User may withdraw consent as easily as giving it,
without affecting earlier lawful processing. TBW will explain a refusal
or necessary limit and the available complaint route. The one-month
response period and any permitted extension are applied under the
relevant law.
15.3. Complaints.
User may contact TBW to exercise rights. User may also complain to
the competent supervisory authority, including the authority in User’s
habitual residence, workplace or place of an alleged infringement. In
France, this is the Commission nationale de l’informatique et des
libertés (“CNIL”); in the UK, the Information Commissioner’s Office
(“ICO”). User need not obtain TBW’s approval to complain.
15.4. Additional French rights.
Subject to French law, User may give, modify or withdraw instructions
concerning retention, deletion and disclosure of Personal Information
after User’s death and identify a person to carry them out. Submit
specific instructions to info@bodywellmethod.com. Acceptance of the
Terms is not a substitute for that instruction. In the absence of valid
instructions, TBW will apply the rights and limitations established by
law. Privacy information and consent requests will be provided in the
language required for the relevant offering.
16. CANADA, INCLUDING QUÉBEC.
16.1. Consent and
accountability.
Where Canadian federal or provincial private-sector privacy law
applies, TBW identifies appropriate purposes, limits information to what
is reasonably needed and obtains meaningful consent or relies on a
specific lawful exception. Express consent is obtained for sensitive
health information where required. Optional purposes are distinguished
from those necessary for the requested service. User may request access
and correction and withdraw consent to future processing, subject to
lawful restrictions and an explanation of any resulting loss of the
particular feature.
16.2. Overseas processing
and complaints.
Canadian information may be processed outside Canada, including in
the United States and other countries in which the service providers
identified in Section 6.1 operate, and may be accessible to authorities
under those countries’ laws. TBW remains accountable for information
entrusted to service providers to the extent required by law. Questions
or complaints may be sent to info@bodywellmethod.com; User may also
contact the Office of the Privacy Commissioner of Canada or the
competent provincial authority, including Québec’s Commission d’accès à
l’information (“CAI”).
16.3. Québec privacy
officer and governance.
Person in charge of the protection of Personal Information: Privacy
Officer, TBW Method Inc.; contact: info@bodywellmethod.com, attention
“Québec Privacy Officer.” TBW’s governance practices assign
responsibility for authorized access, retention and destruction,
handling requests and complaints, and responding to confidentiality
incidents. Necessary assessments are performed for covered systems and
cross-border disclosures. Default privacy settings, consent for
identification, location or profiling technologies, and portability are
implemented as required by Québec law. No such optional profiling or
location function is activated merely through acceptance of this
Policy.
17. AUSTRALIA.
Where the Privacy Act 1988 (Cth), Australian Privacy Principles or
other applicable Australian privacy law covers the processing, TBW
collects information reasonably necessary for its functions, obtains
consent for sensitive health information where required, and limits use
and disclosure to lawful purposes. Overseas disclosures are subject to
applicable accountability requirements and the transfer practices
described in Section 14.
Australian Users may request access or correction and complain at
info@bodywellmethod.com, attention “Australian Privacy Complaint.” TBW
will review and respond within a reasonable period, generally thirty
(30) days for a privacy complaint, and explain any refusal or further
steps. User may also complain to the Office of the Australian
Information Commissioner (“OAIC”).
18. CHILDREN; POLICY CHANGES.
18.1. Adults only.
The Services are intended for individuals who are at least eighteen
(18) years old and, if higher, the age of majority in their
jurisdiction. TBW does not knowingly collect Personal Information from
ineligible minors. If TBW learns that an ineligible minor has provided
information, it will take appropriate steps to restrict the account and
delete the information, subject to a specific legal retention duty.
Contact info@bodywellmethod.com to report a concern. A parent’s
permission alone does not make a minor eligible for the Services.
18.2. Updates.
TBW may update this Policy to reflect lawful changes to practices or
requirements and will update the date above. Material changes will be
brought to User’s attention through email, an in-app notice or another
appropriate prominent notice before new processing begins, with advance
notice where required. TBW will obtain fresh consent or authorization
when law requires it, including before materially expanding
consent-based health-data purposes. Continued use is not deemed consent
to a new sensitive-data use or a waiver of privacy rights.
19. CONTACT INFORMATION.
TBW Method Inc., doing business as The BodyWell Method
Mailing address: 30 N Gould Ste 100, Sheridan, WY 82801, United
States | Customer contact telephone: 316-308-1149
Privacy questions, rights requests, complaints and appeals:
info@bodywellmethod.com
For consumer health data: use the subject “Consumer Health Data
Request” or “Consumer Health Data Appeal.”
